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Payment and e-money application gap checker.

Identify FCA application gaps before submitting an SPI, API, small EMI or EMI application, with a readiness score and the items to complete in order of priority.

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Sixteen questions on your application pack and the team behind it, set by the application type. The result appears on this page.

Which application are you preparing?
Is a regulatory business plan written for your own business, with a three-year budget forecast?
Does the business plan show when the firm breaks even and becomes profitable, with pricing, volumes, costs and funding runway you can back up?
Is there a flow of funds showing every account, party and step that customer money passes through?
Do the CEO, directors and persons responsible for payment services have the skills, knowledge and track record their roles need, with evidence the FCA can check?
Has the MLRO run financial crime controls for products, customers and countries like yours, with the time and authority the role needs?
Is every controller holding 10% or more identified, with ownership chart and source of wealth evidence?
Is the safeguarding arrangement designed, with a safeguarding account provider identified?

Small payment institutions may choose to safeguard; answer for the arrangement you will run.

Are the business-wide risk assessment and AML and sanctions policies written for your own customers and products?
Have you identified the key operational, financial, financial crime and security risks, each with a mitigation that names the system, the process and the person responsible?
If you lost a key supplier, your bank account or your systems, is there a tested plan to return to normal service within a set time?
Are the incident reporting, complaints handling and data protection procedures written for the firm?
Are your outsourced providers selected, with due diligence and agreed terms?
Is a wind-down plan prepared, showing how customers are repaid if the business closes?
Is the FCA application form drafted, with every question answered and cross-referenced to your documents?
Answer each highlighted question to see your result.

How the result is worked out.

The rules the tool applies, in full. The result is guidance from your answers.

Each answer scores 2 for “In place”, 1 for “In progress” and 0 for “Not started”. Priority items count double. The score is the total as a percentage of the maximum for the questions that apply to your firm.

ResultScore
Ready for final review85% or above, with no priority item at its lowest answer
Targeted work before submission60% to 84%, or 85% and above with a priority item at its lowest answer
Build the foundations firstBelow 60%

Priority items

  • Regulatory business plan
  • Path to profitability
  • Flow of funds
  • Initial capital
  • Financial resources under stress
  • Competence of the leadership team
  • MLRO competence
  • Controllers
  • Safeguarding arrangement
  • Financial crime framework
  • Wind-down plan

The initial capital and stress questions apply to authorised payment institutions and authorised EMIs, which hold initial capital before authorisation. Priority items are those the FCA most often returns an application for, according to its published feedback on payment and e-money applications.

Questions firms ask.

Why check an application before submitting it?

The FCA assesses an application as submitted. A complete application starts the three-month statutory period; missing or generic documents lead to questions that extend the assessment, or to the application being returned.

Which items does the FCA most often question?

Business plans written from templates or with no credible route to profit, leadership teams and MLROs without experience of the business, unclear flows of funds, capital without evidence of its source, financial crime frameworks that do not match the business, and wind-down plans without costs or triggers.

Does the checker cover small institutions?

Yes. Choose the application type first; the questions that apply only to authorised firms, such as initial capital, are hidden for small payment institutions and small EMIs.

Is my result stored?

No. The check runs in your browser and nothing is sent unless you choose to send the result to us through the contact form.

What does a pre-submission review involve?

A review of the full pack against the FCA’s form and its published expectations, with each gap and inconsistency set out in writing and closed before submission.

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Further reading.

Guide

Applying for FCA Authorisation in 2026: How to Ensure a Successful Application Outcome

How to apply for FCA authorisation in 2026: threshold conditions, documents, 2026/27 application fees, FCA timelines, the Connect process and next steps.

Guide

How Long Does an FCA Payment Institution or EMI Licence Take in 2026? Realistic Timelines and Delays

How long FCA PI and EMI authorisation takes in 2026: 3 and 12 month statutory limits, the FCA's 219-day median, 6 to 8 month planning and what causes delay.

Guide

How Much Does an FCA PI or EMI Licence Cost in 2026? Fees, Capital and Real Application Costs

FCA PI and EMI licence costs in 2026: £1,130 to £5,640 fees, €20,000 to €350,000 capital, 2026/27 periodic fees, own funds examples and a full launch budget.

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A reply within three business hours and a written proposal on the licence, the requirements, the cost and the timing the same day.

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